Case 3:14-cr-00023-KRG-KAP Document 241 Filed 03/25/16 Page 1 of 2

IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF PENNSYLVANIA
UNITED STATES OF AMERICA
v.
JOSEPH D. MAURIZIO, JR.

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Case No. 14-23J

UNITED STATES MOTION TO RESTRAIN ASSETS

AND NOW comes the United States of America, by its attorneys, David J. Hickton,
United States Attorney for the Western District of Pennsylvania, and Stephanie L. Haines,
Assistant United States Attorney for said district, and hereby moves the Court pursuant to the All
Writs Act, 28 U.S.C. 1651, and Section 3202(a) of the Federal Debt Collections Procedures
Act, 18 U.S.C. 3001 et seq., for an order restraining for a period of 60 days defendant Joseph
D. Maurizio, Jr., Christine Shaulis, and the Joseph D. Maurizio, Jr. Revocable Trust, along with
their agents, representatives, beneficiaries, servants, employees, attorneys, persons with power of
attorney, family members, and those persons in active concert or participation with them, and
anyone holding property, both real and personal, including escrow, bank, retirement, or
insurance accounts, owned or controlled by defendant or transferred from defendant, from
selling, transferring, assigning, pledging, distributing, giving away, encumbering, or otherwise
participating in the disposal of or removal from the jurisdiction of this Court, or removal from
any escrow, bank, retirement, or insurance account, of all or part of the defendants interest,
direct or indirect, in all such property, real or personal, without prior approval of the Court and
upon notice to the United States and an opportunity for the United States to be heard.

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A Memorandum of Law in support of this Motion is being filed contemporaneously

herewith and is incorporated by reference herein.
WHEREFORE, the United States respectfully requests that the Court issue an order
restraining dissipation of assets as set forth in the accompanying Proposed Order.

Respectfully submitted,
DAVID J. HICKTON
United States Attorney
/s/ Stephanie L. Haines
STEPHANIE L. HAINES
Assistant U.S. Attorney
200 Penn Traffic Building
319 Washington Street
Johnstown, PA 15901
Phone: (814) 533-4547
Fax: (814) 533-4545
Email: stephanie.haines@usdoj.gov
WV 9249

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IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF PENNSYLVANIA
UNITED STATES OF AMERICA
v.
JOSEPH D. MAURIZIO, JR.

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Case No. 14-23J

RESTRAINING ORDER
This matter is before the Court on the Motion the United States of America for a
restraining order pursuant to the All Writs Act, 28 U.S.C. 1651, which provides the Court with
authority to enter a restraining order and to take such other action in connection with any
property subject to an order of restitution and/or fine to ensure its availability for payment of
such fine and/or restitution.
Based upon the briefs and arguments of counsel and upon all the files, records, and
proceedings herein,
IT IS HEREBY ORDERED that the United States Motion is GRANTED; and it is
FURTHER ORDERED that for a period of 60 days from the date of this Order, defendant
Joseph D. Maurizio, Jr., Christine Shaulis, and the Joseph D. Maurizio, Jr. Revocable Trust,
along with their agents, representatives, beneficiaries, servants, employees, attorneys, persons
with power of attorney, family members, and those persons in active concert or participation
with them, and anyone holding property, both real and personal, including escrow, bank,
retirement, or insurance accounts, owned or controlled by defendant or transferred from
defendant, be and are hereby enjoined and restrained from selling, transferring, assigning,
pledging, distributing, giving away, encumbering, or otherwise participating in the disposal of or
removal from the jurisdiction of this Court, or removal from any escrow, bank, retirement, or

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insurance account, of all or part of the defendants interest, direct or indirect, in all such property,
real or personal, without prior approval of the Court and upon notice to the United States and an
opportunity for the United States to be heard. The United States is hereby authorized to record a
notice of lis pendens on any real property owned or co-owned by defendant, or transferred from
defendant, or file any other documents to ensure the property is preserved for payment of any
fine and/or restitution. The property subject to this order includes, but is not limited to, the
defendants interest, whether joint or exclusive, in any RETIREMENT ACCOUNT, BANK
ACCOUNT, FINANCIAL INVESTMENT ACCOUNT, INSURANCE POLICY, AND REAL
PROPERTY.
RESTRAINT OF ASSETS HELD AT FINANCIAL INSTITUTIONS
IT IS HEREBY ORDERED that for a period of 60 days from the date of this Order, the
accounts and other property of the defendant maintained in escrow or at financial institutions in
the United States be and the same are frozen. Those holding funds in escrow or at financial
institutions, or holding investment accounts or insurance policies, are directed to prevent and are
otherwise enjoined from transferring (by wire or otherwise), conveying or disposing of all
monies or other property currently within any accounts or safe deposit boxes of the defendant.
In ordering the funds in escrow or at financial institutions frozen, it is the intention of the Court
that demands to the correspondent institutions to release any money not be honored nor shall
those holding funds in escrow or at financial institutions, or holding investment accounts or
insurance policies, honor any checks or other negotiable instruments drawn on the accounts of
the specific banks, if to do so would reduce the balance of the account below the amount frozen.
It is directed that those who hold funds in escrow and at financial institutions and/or that
maintain accounts identified herein shall immediately inform the government agents who serve

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the certified copies of this order of the account balances on the date of service. Such persons are
further directed to continue to receive and credit monies to the defendants accounts.
The United States is authorized and directed to serve a copy of this Order on defendant
and any other entity or individual the government believes may be in control or possession of
property of defendant affected by this order by certified mail.

IT IS SO FOUND AND ORDERED this ______________ day of ________________,

2016.

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THE HONORABLE KIM R. GIBSON
UNITED STATES DISTRICT JUDGE